ROCK ISLAND ARSENAL, Ill. – The Designated Disposition Authority is an essential function of the Joint Munitions Command’s demilitarization mission. DDAs provide disposition instructions for excess, obsolete, and unserviceable government-owned ammunition items and components that need to be demilitarized to ensure compliance with Environmental Protection Agency regulations and the associated statute, which requires the Department of Defense to have DDAs. “DDAs are a network of trained DoD environmental protection specialists, demilitarization managers, and logistics personnel that implement the U.S. Environmental Protection Agency Military Munitions Rule statute and the associated DoD Procedures,” said Celia Hadden, Director, Demilitarization at HQ, JMC.
The Military Munitions Rule is statute implemented by a joint regulation between EPA and DOD that clarifies when excess military munitions are a solid waste that also meet criteria to be designated a hazardous waste by EPA regulations. The implementing procedures ensure safe storage, handling and transportation of these items.
Waste Military Munitions are items that are abandoned, damaged or deteriorated beyond repair, identified for treatment and disposal, or designated a waste munition by an authorized military official. A WMM becomes a Hazardous Waste Munition if it is toxic, reactive, ignitable, or corrosive. Installations that store HWM are required to conduct a quarterly inspection and an annual inventory of the hazardous waste material to ensure the items remain stable. If the HWM contains liquid, the item must be stored in a facility with a secondary containment system to contain spills.
The DDA responsibilities include determining when excess munitions are a WMM item under the EPA rules, facilitate the notification to sites receiving HWM items to ensure the proper handling, transportation, and storage standards are observed, and coordinate with Program Managers, Item Managers, and demilitarization sites to ensure that the items are destroyed in compliance with environmental regulations. As part of their duties, DDAs also evaluate the various resource, recovery, and recycling options for the excess material before declaring the munition item a WMM and potentially a HWM subject to regulation by EPA.
Service DDAs provide the centralized process to evaluate and declare excess items a hazardous waste military munition (when required). This ensures that there is consistent interpretation and application of the Military Munitions Rule requirements across DoD. “Only DDAs can reclassify assets as a waste military munition, Condition Code V, which designates it as HWM, said Hadden. CC-V is the ammunition supply code that designate a material as a hazardous waste military munition and must meet EPA labeling and storage requirements before demilitarization. “Unnecessarily assigning CC-V adds cost and logistics burden by requiring additional storage and inspections at the demilitarization site. Not designating munitions as HWM when they actually are hazardous can subject the storage site to an EPA violation and fines and potentially expose personnel to hazards in the event of an accident or spill”, she added.
“The required annual DDA training is the key to ensure that everyone knows and understands when and how to apply the Military Munitions Rule correctly and consistently” said Cory Britt, HQ, JMC ammunition demilitarization specialist. Britt helps arrange the training class each year for the 14 DoD DDAs who provide disposition support to their respective Services and coordinate with HQ, JMC to execute demilitarization of their excess material. The training is also made available to National Guard Bureau and Reserve Component soldiers and demilitarization and logistics personnel, to include government and contract employees.
DoD contractors and soldiers familiar with the Military Munitions Rule will understand the storage and handling requirements for waste military munitions and are more prepared to comply with these requirements when they are generator of hazardous waste munitions, or receive munitions designated as HWM from HQ, JMC storage sites under commercial demil contracts.
The DDA evaluation process aligns and expedites the review of the munition items to ensure that logistics requirements to accept and demilitarize the material (e.g., proper item identification, inventory tracking and accountability, safe storage and transportation, munitions characterization, environmental reporting, and funding) have been met to safely demilitarize the material, reduce any explosive hazard associated with the item, and free up valuable storage space at DoD facilities.